Translated via Google and patched together as best I could - there are gaps that I am unsure how to fix
Ministry of Food, Agriculture and Fisheries • Holbergsgade 6 • 1057 København K
The Animal Ethics Council • detdyreetiskraad@fvm.dk • www.detdyreetiskraad.dk
In the Council’s view, there is a need for a cultural change in equestrian sports, and the Council sees a focus on respect for the horse as a crucial prerequisite for actually being able to promote the welfare of horses when they are used for sport. The council considers that there is a need for horse welfare
With this request, the Animal Ethics Council would like to draw attention to the food minister’sattention to animal welfare in connection with the use of horses for sport. The Danish Council on Animal Ethics issued a statement on the use of horses for sport in March 2023. In the opinion, the Council pointed to matters where the Council assessed that there is a need for legislative initiatives. At the same time, the council proposed in some areas to give the horse sports organizations the opportunity to launch initiatives themselves to prevent the horses from suffering physical and mental harm in connection with training and the holding of sporting activities.
it is not in itself problematic that horses are used for sport, but the use entails a risk that the horses’ welfare is compromised. The council stressed that it is unacceptable for horses to suffer pain, wounds and other discomfort when performing sporting activities. The Council emphasized here that the recommendations should lead to immediate action by the industry. If the follow-up did not happen as soon as possible, and otherwise within a year’s time, the Council would recommend that specific legislation be drawn up in Denmark for the use of horses for sports.
Since the publication of the statement, the Animal Ethics Council has been continuously informed by the Forum for Horse Welfare (a platform for a number of organizations relating to horses) about the status of the measures that have been taken and are planned in the organizations with a view to increasing the focus on the welfare of sport horses. The Animal Ethics Council finds it very positive that the organizations have started this work, which certainly contains steps in the right direction, and the Council also understands that some initiatives require time to implement.
However, the Animal Ethics Council finds that there is a much greater need to focus on preventing mental and physical overload of the horses than is reflected in the material from the Forum for Horse Welfare. In its statement, the Animal Ethics Council pointed out that there is a need to do away with the view of the horse as an athlete and recognize that the horse is an animal with its own biological needs and limitations, and that the use of horses in sports is only about human interests and ambitions. The Council notes that in the follow-up material that the Council has received from the Forum for Horse Welfare, concepts about the horse such as “fit to compete” and “positively accepting” are used. The Council finds that these terms reflect an approach where, at least for some, the horse is still primarily regarded as a sporting tool, and the Council misses that respect for the horse and safeguarding its welfare is put at the center as a focal point that is significant in itself.
The Danish Council on Animal Ethics takes the recommendations from the statement on the use of horses for sport as a starting point. The Council considers this as a contribution to the work of establishing legislation in the area and not necessarily as an exhaustive list. The Council examines the topics of education, training and use of equipment, as well as doping and other performance-enhancing measures, which are the areas where the Council assesses that the need for legislation is greatest. However, the Council would also like to encourage that, in connection with the preparation of legislation, consideration be given to whether other matters in relation to the use of horses for sport should also be covered by statutory regulation, cf. the other recommendations in the Council’s statement, e.g. checking the horses both before and after competition.
The Danish Council on Animal Ethics also pointed out in its statement that life as a sport horse can involve some special challenges beyond those directly related to training and competition, e.g. in the way they are kept. The Council has therefore also made a number of recommendations in the statement that are aimed at, among other things, age for introduction, need for exercise and social contact, and transport. The Council calls for these recommendations to also be included in the legislative considerations.
Education
The Animal Ethics Council argued in the opinion on the use of horses for sport that it is crucial that the level of knowledge of the people who deal with horses is up to date. The council considers this knowledge to be a prerequisite for being able to respond appropriately to the horse’s behavior and signals in general, including signals of pain and discomfort as well as conflict behaviour. This need for education and knowledge about horse welfare is particularly urgent when it comes to people who have to do with sport horses, as these horses are at risk of being exposed to great pressure due to the competitive element.the organizations can only make demands in relation to that which takes place under its own auspices, and the Council believes that there is a need to ensure rules that apply to everyone regardless of any organizational affiliation.
The Council would like to emphasize that the Council considers legislation to be a supplement to, not a substitute for, the work that the equestrian sports organizations themselves have initiated. The Council also continues to believe that some of the Council’s recommendations in the opinion on the use of horses for sport can best be handled by the organizations themselves. The Council therefore also recommends that the organizations continue their work as planned. The Danish Council for Animal Ethics elaborates below on its considerations and recommendations in relation to legislative initiatives. The Animal Ethics Council has therefore decided to recommend that the Minister of Food draw up more detailed legislation for the use of horses for sport in order to ensure some minimum limits that must be observed, regardless of the sports discipline, associated organization and possibly personal membership.is put in the center with far more measures than outlined by the organizations themselves – and measures that contain mandatory and more specific requirements, with concrete deadlines for implementation and options for sanctions in the event of violations. At the same time, the Council has the impression that there are widely varying standards among the various equestrian sports disciplines, and the Council considers that there is a need to set some boundaries across sports disciplines, based on the welfare of the horses.
The council therefore believes that the need for training applies in particular to those who are responsible for teams of horses, training, teaching and holding competitions.
Training of employees in companies with teams of horses
In October 2024, the Danish Veterinary and Food Administration issued a consultation on a proposal for a law amending the Animal Welfare Act. Here a proposal was made regarding Section 21 of the Animal Welfare Act, on setting training requirements in relation to animal welfare for employees in companies with agricultural keeping of animals. It emerged from the consultation material that the change is initially thought to be applied in relation to herds with pig production. However, the Animal Ethics Council recommended in its response to the consultation on changes to the Animal Welfare Act, that the training requirement is also applied in relation to other types of herds. As an extension of this, the Animal Ethics Council will therefore further recommend that Section 22 regarding the training of persons in relation to horse keeping be revised, so that here too it becomes possible to set requirements for the training of employees, and that this option is used as soon as possible.
Quality of the educations
As mentioned above, the Council considers this knowledge to be a crucial prerequisite for being able to respond appropriately to the horse’s behavior and signals.
Training of the person responsible for commercial horse keeping
teams of horses should be exempt from similar training requirements.
The Animal Ethics Council recommends that rules be laid down for the training of the person responsible for a professional team of horses, e.g. riding schools, cf. the possibility in Section 22 of the Animal Welfare Act to make such demands (Announcement of the Animal Welfare Act, LBK no. 61 of 19/01/2024). Corresponding requirements are imposed on persons who are responsible for the commercial keeping of pigs, dairy cattle, broiler chickens, laying hens, mink and dogs, and requirements are also imposed on pet traders and on persons involved in the commercial transport of a number of animal species (including horses). The council sees no reason to, in terms of business
The Council therefore considers it essential that the standard is ensured by role models such as riders and trainers, who bear a responsibility for imparting knowledge and good practice in training and using the horses, as well as by judges, who through their awards show what behavior is acceptable.It must also be ensured that the education is up-to-date in terms of knowledge about training methods and standards for horse welfare.
The Animal Ethics Council is aware that a number of educational initiatives have been taken under the auspices of the equestrian organisations, which the Council welcomes.However, the council believes that there is a need to ensure that training courses are made compulsory for all relevant parties, and that there is impartial quality assurance of the content.As an extension of this, the Animal Ethics Council also recommends that it is ensured that the courses in question sufficiently cover knowledge of horse behaviour, including conflict behaviour, as well as knowledge of horse welfare, also outside of training and competition, e.g. in connection with transport and housing .
Evaluation of the use of equipment for horses
The Animal Ethics Council recognizes that equipment can have an important function in helping to give clear signals to the horse about what you want it to perform. But the Council considers that there is a need to evaluate the use of equipment, so that this is not used to force the horse to perform inappropriate movements or push it too hard, e.g. due to the rider’s (too high) ambitions.
The Council thus emphasizes that equipment must be used with caution and to guide the horse, not as part of physical coercion by causing pain and discomfort.Against this background, the Animal Ethics Council recommends an overall rethinking of the use of equipment. In the Council’s view, equipment and aids should be reviewed based on up-to-date standards and knowledge of animal welfare. In its opinion, the Council initially recommended that the equestrian organizations themselves take responsibility for this evaluation, and the Council outlined the principle guidelines that the Council believes should form the basis of the evaluation.
The council considers that it is unacceptable that horses are inflicted with pain, wounds and other discomfort in the exercise of sporting activities, and this must stop immediately. In continuation of this, in its opinion on the use of horses for sport, the Council reminded of the current legislation, namely that horses cf. The Animal Welfare Act (LBK no. 61 of 19/01/2024) must be protected as best as possible against pain, suffering, anxiety, lasting but significant inconvenience (§ 2), and that horses must not be trained or used for display or the like, if they thereby significant disadvantage is inflicted (§ 28), and that the equipment used as aids on horses, in accordance with the horse order (Order on minimum animal welfare requirements for keeping horses, BEK no. 1746 of 30/11/2020) may not cause damage to the horse or be used as means of coercion (§ 28).
In connection with the preparation of the statement, the Council was generally concerned about whether the practice, which is seen in some cases when horses are pushed in connection with the practice of equestrian sports, lives up to the intentions of these paragraphs. This concern has been further strengthened by events that have taken place since the publication of the opinion.
The Animal Ethics Council has discussed the use of equipment such as bits and reins, whips and spurs.
Training and use of equipment
However, since the publication of the Animal Ethics Council’s opinion in March 2023, the Council has continued to see worrying examples of sport horses showing signs of discomfort, pain and conflict behaviour. The council has also followed the debate in continuation of various broadcasts about welfare and equestrian sports as well
The Animal Ethics Council is aware that the equestrian organizations have initiated the proposed evaluation work. However, the drafts for this which the Council has received are not sufficient compared to the occurrence of signs that the welfare of the horses is still under pressure. The council initially did not set out to ban certain types of equipment, but pointed out that the evaluation should take into account the fact that even though some equipment may be used in certain situations without discomfort and the like. for the horse, the equipment in question may be so difficult to use correctly that the use
Keeping the head and neck in a certain position has been the subject of much attention in recent years, as more knowledge has come about the consequences of restricting the horse’s freedom of movement. The crooked neck is typically referred to as “roll cure”, “hyperflexion” or “low deep round”.
Examples of legal measures
Research shows that a curvature of the neck, where the bridge of the nose is held behind the vertical,The Danish Animal Ethics Council believes that the focus of the evaluation should be particularly on the use of complex types of bites, the tightness of nosebands, the tightening of reins and auxiliary reins, as well as clear criteria for the use of whips and spurs.should either be discontinued altogether or limited to persons who are specially qualified to both use the equipment and at the same time be able to assess the horse’s possible conflict behavior or signals of discomfort or pain. In light of the documentation and debate that has taken place since the publication of the Council’s opinion, where signs of discomfort, pain and conflict behavior can still be observed in even the highest-awarded riders’ horses, the Council today assesses that there is a need to legally prohibit certain types of equipment and prohibition on the use of bits that entail a significant risk of cutting off the blood supply to the horse’s tongue, e.g.
The council specifically recommends the following legislative measures:
specify the permitted use by others.
Establishing a limit for how tight the noseband must be, as well as Prohibition on the use of spurs and whips with a force that has the character of punches and kicks.
Ban on the use of tongue ties. The council notes that the relevant equestrian organizations themselves have decided to prohibit this in their own rules from 1 January 2025.
Principles for evaluating the use of equipment
The Animal Ethics Council recommends, in continuation of this, that it is ensured that the use of equipment i.a. complies with the following
principles:
Equipment must only be used to guide the horse to understand what it needs, not for coercion or punishment.
an instruction on how this is measured.
The Danish Council on Animal Ethics also draws attention to the fact that in some disciplines there may be a desire for the horse to hold its head and neck in a specific position. This is achieved with a combination of training and equipment.
Equipment must not change the horse’s natural movement pattern, inhibit the horse’s senses or physiology, or lock a body part or the horse’s body position, so that the horse shows signs of e.g. discomfort, pain or conflict behaviour, and equipment must not hinder the possibilities of being able to read the horse’s signals about this.
The council notes that certain types of equipment are prohibited from being used for dogs, and that cf. The Animal Welfare Agreement’s initiative no. 3 are plans to tighten these rules further. The council recommends that the same criteria for accepting the use of equipment as the basis for banning equipment for dogs be used when evaluating the use of equipment for horses.
The Animal Ethics Council emphasizes that the recommendations for specific legal measures should not be considered exhaustive, but are merely examples of the level that the Council believes should be used as a basis for the recommended evaluation of the use of equipment.
The council notes that in their evaluation the horse sports organizations themselves also point to equipment that should be prohibited (e.g. use of sliding reins), or where there is a need for clarification of permitted design or use of equipment (e.g. track length). The council recommends that these initiatives be included in the legislative considerations.
Doping and other performance-enhancing measures
If a horse is injured, the Animal Ethics Council believes that it must be treated if necessary and otherwise given the necessary rest and rehabilitation before it is ready to enter competitions again. In the Council’s opinion, agents intended to camouflage pain and injuries, or to otherwise promote the horse’s performance, should not be used. This applies both in relation to medication and other measures, and it is also not allowed according to section 29 of the horse order (BEK no. 1746 of 30/11/2020).for keeping horses (BEK no. 1746 of 30/11/2020)
Prohibition against subjecting horses to exercises that they are not physically or behaviorally suitable to perform, e.g. holding the bridge of the nose vertically behind.
Requirements that horses must be trained according to principles that do not disregard their welfare. (BEK no. 1750 of 30/11/2020) demands are made that animals must be trained according to principles that do not disregard the welfare of the animals, and that the animals must not be subjected to exercises in connection with training or performance that the animals in question are not physically or behaviorally suitable to perform (Section 17). The Animal Ethics Council sees no reason why horses that are part of a sporting context should be exempt from similar requirements. The Council therefore also recommends the following:
typically results in a sharp angulation of the horse’s throat and can change the angles in other parts of the horse’s anatomy, which can increase the risk of problems in both the back and legs. The stuck and possibly Crooked neck can also limit the horse’s field of vision, and both this and inhibitions in the throat, airways and/or the ability to move the head and neck freely can make the horse insecure and anxious. The Council notes that in the Executive Order on keeping and displaying animals in circuses, etc
However, the Animal Ethics Council finds that there is a need to look more closely at the gray zone, where, for example, an approved pain treatment means that the horse can participate in a competition where it might otherwise have had a reduced performance due to pain or even been lame. Although, according to Section 29 of the Horse Order, it is not permitted to use any kind of medication or treatment that aims to hide symptoms of illness so that the horse can train and participate in competitions, the text does not directly prohibit a horse that has, for example, been treated for pain with a view to pain coverage, subsequently – where it no longer shows lameness – will actually be able to participate in a competition. However, the council does not believe that one with
Clarification of § 29 in the executive order on minimum animal welfare requirements
The Animal Ethics Council notes that Section 29 of the Animal Welfare Act provides the opportunity tolay down rules prohibiting animals that have been subjected to operative and similar interventions to be exhibited or displayed in any other way for the purpose of assessing the animal’s appearance, utility or skills. Within some equestrian disciplines, according to their own rules, it is not permitted to participate in competition on horses that have had a neurectomy (also called nerve cutting, which is an operation in which nerves to a painful area, e.g. a sore hoof, are cut, so that the horse cannot feel the pain). The council recommends that the option in Section 29 of the Animal Welfare Act be used to establish a ban on horses that have undergone surgical interventions that have an impact on performance, e.g. nerve cutting, from participating in competitions and the like.
The Animal Ethics Council further recommends that there be a requirement that the medication of sports horses be registered, and that surgical interventions that have an impact on the horse’s performance, e.g. nerve cutting, must be listed in the horse’s passport, as these measures can otherwise be difficult to demonstrate. The council recommends that, as an extension of this, there is also a requirement that medication registration and horse passports must be checked prior to competitions, and this information must therefore be made available to the persons who must carry out checks on the horses at competitions. Horses that are still within the effective period of medical treatment or have undergone surgical procedures that affect performance must be refused entry.
Use of section 29 of the Promulgation of the Animal Welfare Act (Animal Welfare Act)(LBK no. 61 of 19/01/2024)
In connection with the preparation of the statement on the use of horses for sport, the Danish Council for Animal Ethics was informed by the Danish Veterinary and Food Administration that it is the Danish Veterinary and Food Administration’s assessment that, according to the provision, the horse can only participate in competitions when it is symptom-free, i.e. the disease is assessed as over or the injury is assessed as healed, and when the medicine with which the horse has been treated can no longer hide the symptoms of the disease. The Council has noted the Danish Veterinary and Food Administration’s assessment of the intention of Section 29 of the Executive Order on Horses, but the Council recommends that it be specified directly in the Executive Order that if the horse has received treatment that could affect its performance, it may not participate in competitions until the effect of the treatment can be expected to have ceased, so as to ensure that any symptoms are not alleviated by the medicine and that the horse has actually recovered from its illness or injury. reference to the need for e.g. pain coverage nevertheless must be able to make horses “usable” for competition, if the horse would not be able to perform, or perform as well, without the treatment.
The Animal Ethics Council is of course available for an elaboration of the above and dialogue on further measures.
Sincerely,
Bengt Holst, Chairman of the Animal Ethics Council